October 27, 2010
Re: File Number S7-15-10
Having been a licensed insurance professional and a registered representative for over 30 years, I would like to share my opinion on this proposed change.
While I support the new SEC rule 12b-2 to continue the 25 basis points fee for providing ongoing service and advice to my clients, I fear the people you want to protect the most (middle and lower market investors) will be hurt the most with your idea of permitting mutual funds to issue a new class of shares at net asset value wherebt broker-dealers can set their own sales charge and commission fee. I strongly object to this idea.
As broker-dealers lower their sales charges and fees to gain market share, it will no longer be feasable financially for registered reps such as myself to continue to provide the level of individualized advice and ongoing service to our middle and lower market clients.
I fear only the upper-income investors who can afford assets-under-management arrangements and willing to pay a fee will receive personalized advice. This will force the smaller account holders to move to self-direct accounts and advisors such as myself will no longer be able to afford to spend the time to guide and advise them.
Thank you for listening,